During an eRate training session in Washington, D.C., on Sept. 30, USAC’s Catriona Ayer listed the 10 primary reasons eRate applications are denied:
Applications request ineligible products and services. If 30 percent or more of the services requested in an eRate funding application are deemed ineligible, the application is automatically denied. This is known as the "30 Percent Rule," Ayer said; the best way to avoid an automatic denial because of this rule is to "break out," or separate, funding requests as much as possible. When in doubt, she said, do the math. If your calculations for ineligible services come in over 30 percent, revise your application before submitting it to USAC.
Contracts are not signed or aren’t in the right place. When asked to supply contract information, make sure the documents are signed and are included in the right place throughout your funding application. If there is no signature, or if the reviewer cannot find the appropriate documentation within the application, Ayer said, USAC has no choice but to deny the request.
Applications include unauthorized consortium members. If you’re applying with an education service agency or consortium, Ayer said, make sure you have the proper Letters of Agency–and that you meet the requirements posted on the SLD web site. If not, your application will be denied.
Insufficient documentation. USAC requires applicants to be prepared to respond to a Program Integrity Assurance Review with copies of their service contacts and other relevant document information. If the documentation is lost or cannot be located in time, Ayer cautioned, the application could be denied. Applicants must keep all documentation for five years after their initial application is submitted. Failure to do so could lead to penalties, including potential program disbarment and funding recovery.
Insufficient support resources. Program applicants also must prove that they have the appropriate support resources to complete their intended projects. While the eRate pays for a portion of the technology necessary to make infrastructure upgrades, no amount of program money is intended to fully finance any one project, explained Ayer. To avoid having your application denied, you must secure access to the equipment and resources necessary to complete the upgrade. This includes sufficient funds to pay your share, minus the eRate discount, as well as additional hardware, software, electrical capacity, and support.
A Form 470 is not filed. Applicants are not allowed to extend contracts to service providers until their Form 470 application is posted and approved by USAC.
Competitive-bidding violations. One of the most common–and certainly the most controversial–reasons for denial is a violation of the competitive-bidding process. Throughout the day, USAC officials stressed the need for applicants to engage in a "fair and open" competitive-bidding process, where eligible service providers are given ample opportunity to compete for technology contracts. During this phase, officials warned, no service provider should have contact with the applicant, except with regard to the bid itself. That means no helping with official eRate forms–and absolutely no assistance with creating the technology plan. Remember, bidding is the applicant’s responsibility, "not the service provider’s," Ayer said.
Failing to wait the required 28 days before signing contracts. Once a Form 470 is posted to the SLD web site, applicants must wait 28 days before contracts are signed. Jumping the gun could result in a denial of funds.
Requesting services from an ineligible telecommunications provider. Under eRate rules, telecommunications services must be provided by an eligible provider. These providers, which pay into the Universal Service Fund that supports the eRate, can be found through a search on the SLD web site, officials said.
Failing to certify required forms on time. Submitting and certifying forms are two different things, USAC officials warn. To avoid having your request for funds denied, certify your forms online before the filing window closes.
eRate participants schooled in program rules